Tuesday, December 24, 2013

Washington v. Texas case brief

Washington v. Texas case brief summary
388 U.S. 14 (1967)

CASE SYNOPSIS
Petitioner sought review by certiorari of a judgment of the Texas Court of Criminal Appeals which affirmed his conviction and sentence for murder with malice. The trial court refused to allow petitioner to present testimony from a certain witness on the ground that Tex. Pen. Code. art. 82 and Tex. Code Crim. Proc. art. 711 (1925) prevented persons charged or convicted as participants in the same crime from testifying for one another.

CASE FACTS
During petitioner's trial for murder with malice, the trial court refused to allow him to present the testimony of a certain witness on the ground that participants in the same crime were prevented from testifying for one another by Tex. Pen. Code. art. 82 and Tex. Code Crim. Proc. art. 711 (1925). The state court of criminal appeals affirmed his conviction and petitioner sought a writ of certiorari.

DISCUSSION

  • The court reversed. 
  • The Sixth Amendment right to compulsory process to obtain witnesses in an accused's favor was so fundamental to a fair trial that it was applicable to the states through the Fourteenth Amendment. 
  • The right to compulsory process was violated because petitioner was arbitrarily denied the right to put on the stand a witness who was physically and mentally capable of testifying to events that he had personally observed, and whose testimony would have been relevant and material to the defense. 
  • Common law rules imposing restrictions on witnesses to avoid the risk of perjury had been replaced by the modern view that allowed the factfinder to determine the weight given to testimony by persons of competent understanding.
CONCLUSION
The Court reversed the judgment affirming petitioner's conviction for murder and his sentence.

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